Reyes v. Rasheed

Background

Gerardo Reyes brought a civil-rights action under 42 U.S.C. § 1983, alleging that medical staff at CTF-Soledad violated the Eighth Amendment by acting with deliberate indifference to his serious medical needs. He claimed that cataract surgery had misaligned the lens in his right eye, causing continuing eye pain and headaches. The opinion identifies claims against medical staff Karim Rasheed, Mulligan-Pfile, Mandich, and S. Posson, and against grievance reviewers, including R. Branch. The defendants moved for summary judgment, which asks whether the evidence shows that no genuine dispute of important fact requires a trial.

Medical treatment and evidence

The record showed that Reyes had long-term vision loss, diabetes, and glaucoma. Medical staff referred him to ophthalmologist K. Rasheed, who performed cataract-removal surgery on his right eye on September 30, 2015, and on his left eye on October 14, 2015. Reyes later reported recurring right-eye pain and headaches. Staff repeatedly examined him, prescribed or recommended glasses, pain medication, artificial tears, and other treatment, and referred him for additional examinations and procedures. Rasheed later performed YAG capsulotomies to address posterior capsule opacity, a condition that can affect vision but, according to the opinion, does not cause pain.

Reyes said that Drs. Sweet and Tauchto had determined that his lens was misaligned. The court found that the available records did not support that assertion: Sweet’s records did not identify an observable eye problem, Tauchto’s records were not in the record, and Reyes provided no declaration or other evidence confirming the alleged diagnosis. The court also noted that examinations by optometrists and ophthalmologists found the lens properly aligned. Reyes argued that the summary-judgment motion should be delayed until he received all of his medical records, but the court relied on the evidence before it and found that his unsupported assertion did not create a genuine factual dispute.

Legal analysis

To prove deliberate indifference under the Eighth Amendment, a prisoner must show more than negligence, an accidental mistake, or a disagreement with a medical provider’s judgment. The prisoner must show that an official knew of a substantial risk of serious harm and consciously disregarded it by failing to take reasonable steps to address it.

The court held that the undisputed evidence showed investigation, diagnosis, treatment, and repeated examinations in response to Reyes’s complaints. Nothing in those examinations explained his pain, and the competent medical evidence showed that his lens was not misaligned. The court also rejected Reyes’s claim concerning transition lenses because he offered no competent medical evidence that he medically required them or was harmed by not receiving them. Because Reyes did not show a genuine dispute of material fact concerning the medical staff, the court also found no such dispute concerning the grievance reviewers.

Disposition

The court granted the defendants’ motion for summary judgment in favor of all defendants. It directed the clerk to terminate all pending motions, enter judgment for all defendants, and close the file. Judge William H. Orrick signed the order on February 5, 2020.